• Lucy Kennedy’s unusual and distinctive breadth of knowledge and skill within financial crime is generated by her experience as a prosecution and defence advocate and also by her previous roles within both the Serious Fraud Office and the Financial Conduct Authority. She is valued for her insightful and realistic approach to financial crime and regulation.

    Corporate & Financial Crime

    • Long experience in fraud prosecutions.
    • Defending in serious and international financial misconduct cases: fraud, bribery/corruption, money laundering, tax  evasion, etc.
    • Serious Fraud Office: Case Controller supervising complex bank fraud investigations: LIBOR, EURIBOR, rights issue misrepresentation.
    • Prosecuting and defending in Proceeds of Crime Act confiscation hearings.

    Financial Regulatory 

    • Representing banks and bankers: multi-jurisdictional financial regulatory remediation projects and interbank fraud investigations.
    • Financial Conduct Authority: advising and leading a team on global interbank regulatory misconduct investigation.
    • Appearances before the Regulatory Decisions Committee of the FCA.

    Reviews

    'We really appreciated her constructive approach and invaluable insights on the regulator's expectations… a real pleasure to work with.' Leading European financial institution (2016)

    'We would never have got anywhere close to where we did without her good counsel and patience.' Leading UK financial institution (2015)

    'An uncommon range of experience, providing not only intricate advocacy but also financial conduct guidance.' New Law Journal (2015)

    'Exemplary; impeccable.' Judicial comment (2012) 

    Recent Cases

    R v B (2017-2019) 
    Lucy Kennedy, along with Peter Finnigan QC, defended the CEO of a major international charity in a number of trials in which the prosecution alleged multiple allegations of fraud and receipts of facilitation payments. Lucy Kennedy is presently instructed to defend in complex and ongoing confiscation proceedings.

    FCA v A Global Bank (2018) 
    Lucy Kennedy provided direction to an FCA team conducting a vast regulatory and criminal investigation into an international bank.

    R v T (2016-2017) 
    Lucy Kennedy, with Peter Finnigan QC, defended an international tender-process expert in a World Bank bribery/corruption and money laundering case. 

    Re Bank (2016)
    Authoring an extensive and complex internal investigative report on an interbank fraud and money laundering allegation, for a major international bank.

    Re Bank FCA Remediation (2015-2016)
    Headed a team of sixteen barristers in assisting a global bank with a cross-jurisdictional FCA regulatory remediation.

    SFO Banking Investigation (LIBOR/EURIBOR) (2014)
    Headed two extensive investigations into a leading global bank.

    FCA v H & S (2013)
    Headed a multi-million pound Ponzi scheme investigation/prosecution.

    Re: AC (2012)
    Brokering house CEO financial misconduct allegations.

    R v O (2011)
    Prosecuting an insider fraud within a major bank.

    Graduate & Postgraduate Education

    • BA (Hons) (York): First Class
    • PGD Law & LPC

    Professional Memberships

    • American Bar Association (international member)
    • Association of Regulatory & Disciplinary Lawyers
    • Criminal Bar Association
    • Fraud Lawyers Association
    • Registered with the Bar Council – Public Access Director

    Privacy Notice

     

    Recent Cases

    • Defending, in a number of trials, the CEO of a major international charity accused of multiple counts of defrauding the charity and receiving facilitation payments. 

      ...
    • Lucy Kennedy provided direction to an FCA team conducting a vast regulatory and criminal investigation into an international bank.

      ...
    • International tendering corruption case. Defending a procurement consultant to the World Bank and UNDP (United Nations Development Programme).

      ...
    • Instructed by a UK-based international bank to draft a comprehensive and intricate multi-jurisdictional report examining the merits of associated financial-crime concerns raised by a European state bank.

      ...
    • Lucy Kennedy successfully completed a lengthy international financial-regulatory remediation project across assorted countries, including secrecy jurisdictions, on behalf of a prominent international bank.

      ...
    • Advising the global financial crime division of a leading bank with an international regulatory matter.

      ...
  • Corporate and Financial Crime

    Few barristers have the experience-generated insight of Lucy Kennedy. Her time in court-rooms, law offices, banks and boardrooms has given her an edge of understanding, certainty and persuasion needed and appreciated by both professional and lay clients.

    Experience

    • Areas include: fraud, bribery and corruption, money laundering, tax evasion, etc.
    • Long experience in fraud prosecutions.
    • Defending in serious and international financial misconduct cases.
    • Serious Fraud Office: Case Controller supervising complex bank fraud investigations: LIBOR, EURIBOR, rights issue misrepresentation.
    • Prosecuting and defending in Proceeds of Crime Act confiscation hearings.

    Lucy has in-depth expertise as a financial crime prosecutor and defender. For example:

    • She has prosecuted many financial crime trials over the years.
    • In recent Crown Court trials, she has defended senior individuals charged with fraud; international bribery and corruption; money laundering; tax evasion.
    • She defended against multi-million pound/Euro/dollar international tendering-process bribery and corruption allegations.
    • She defended in trials involving fraud and facilitation payment allegations within the international charity sector.
    • She has prosecuted and defended in Proceeds of Crime Act 2002 confiscations proceedings.
    • She led a large team within the SFO, investigating a major bank.
    • She has led teams within the FCA investigating a large Ponzi scheme fraud and money laundering.

    Notable Cases­

    R v B (2017-2019)
    Defending, in a number of trials, the CEO of a major international charity accused of multiple counts of defrauding the charity and receiving facilitation payments. She is presently instructed to defend in the complex confiscation proceedings.

    R v T (2016-2018)
    International tendering corruption case. Defending a procurement consultant to the World Bank and UNDP (United Nations Development Programme). He was accused of entering into corrupt agreements, over six years, with medical supply companies across Europe regarding their bids for World Bank and UNDP tenders. The tenders were for the supply of medical equipment to hospitals and laboratories across Eastern Europe and Central Asia, totalling £43 million.

    SFO Banking Investigation (LIBOR/EURIBOR/rights issue) (2014)

    • Headed two extensive investigations into a very well-known global bank (the world’s largest at the time).
    • One investigation was into the manipulation of benchmark interest rates, namely LIBOR and EURIBOR, by derivatives traders around the world.
    • A further investigation was into the suspected manipulation of LIBOR by senior executives of the bank and global heads, up to and including its (now somewhat infamous) CEO during the global financial crisis. The investigation enabled the SFO to get to the bottom of what had taken place, thereby facilitating informed, efficient and just decisions as to charge. The comprehensive conclusions exceeded the findings of other national investigative agencies.
    • The rights issue matter looked at the culpability of the bank in its issue of shares prior to the financial crisis.

    FCA v H & S (2013)
    Headed a multi-million pound Ponzi collective investment scheme investigation/prosecution. Over 100 investors were defrauded of more than £5.5 million. The first defendant duped investors into believing their funds would be invested on the foreign exchange markets. His co-defendant recklessly made false representations to investors, promoting a collective investment scheme without authorisation.

    Re: AC (2012)
    Brokering house CEO financial misconduct allegations. Advising a brokering house as to implications arising from the suspected fraud of its CEO.

    R v O (2011)
    Prosecuting an employee of a well-known bank, accused of multiple counts of insider-fraud.

    Recent Cases

    • Defending, in a number of trials, the CEO of a major international charity accused of multiple counts of defrauding the charity and receiving facilitation payments. 

    • Lucy Kennedy provided direction to an FCA team conducting a vast regulatory and criminal investigation into an international bank.

    • International tendering corruption case. Defending a procurement consultant to the World Bank and UNDP (United Nations Development Programme).

    • Instructed by a UK-based international bank to draft a comprehensive and intricate multi-jurisdictional report examining the merits of associated financial-crime concerns raised by a European state bank.

    • Lucy Kennedy successfully completed a lengthy international financial-regulatory remediation project across assorted countries, including secrecy jurisdictions, on behalf of a prominent international bank.

    • Advising the global financial crime division of a leading bank with an international regulatory matter.

  • Lucy's history as a prosecutor and defender in serious and organised crime and white collar crime is evidenced by her aptitude for sharp thinking, notwithstanding complexity. Described by one judge as “hard as nails”, she can be utterly depended upon to safeguard her professional and lay clients.

    Practice evolution:

    Examples of early cases:

    • Junior counsel, prosecuting the notorious Pink Panther Gang, following their £23 million armed robbery of Graff Jewellers in Mayfair in 2004.
    • Junior counsel, prosecuting the country’s largest-ever (£19 million) credit card fraud in 2003.

    Thereafter, for a number of years, Lucy prosecuted complex serious and organised crime cases. She developed a practice in firearms cases and kidnaps, regularly working with Scotland Yard’s kidnap unit.

    For the past dozen years, she has specialised in white collar crime. Early examples of this work include:

    • R v Fontan et al 2013: prosecuting a City commodity broker, accused of blackmail arising out of a failed oil deal.
    • R v Oyewor 2012: Prosecuting a money transfer agent, who committed multi-million, multi-currency international money laundering.
    • R v Ali 2012: Prosecuting a company director accused of shareholder-fund embezzlement.
    • 'Operation Eaglewood' 2009-2011: Largest ever CPS prosecution. International multi-million pound/euro money-laundering case. One of six prosecuting barristers.
    • R v Shoyeju 2011: Cross-continent UK Border Agency senior officer corruption. Leading Counsel for the Crown against Queen’s Counsel.
    • R v Ahmed-Ali & Goss 2011: Prosecuting the fraudulent directors of a gold investment company.
    • R v Oduntan 2010-2011: Prosecuting a bank employee for insider fraud.
    • R v Drake et al 2010: Prosecuting an accountant of a national law firm in an accountancy-fraud and money laundering case.
    • R v Neale 2010: Prosecuting a company director for the fraudulent ‘selling’ of franchise-contracts.

    FCA v H & S (2013)
    In-house at the Financial Services Authority and Financial Conduct Authority, Lucy headed a multi-million pound Ponzi fraud investigation/prosecution. Over 100 investors were defrauded of more than £5.5 million. The first defendant duped investors into believing their funds would be invested on the foreign exchange markets. His co-defendant recklessly made false representations to investors, promoting a collective investment scheme without authorisation.

    From 2013 to 2014 (inclusive), Lucy headed two investigations into a very well-known major bank on behalf of the Serious Fraud Office:

    • One investigation was into the manipulation of benchmark interest rates, namely LIBOR and EURIBOR, by derivatives traders around the world.
    • A further investigation was into the suspected manipulation of LIBOR by senior executives of the Group and global heads, up to and including its (now infamous) CEO during the global financial crisis. The investigation enabled the SFO to get to the bottom of what had taken place, thereby facilitating informed, efficient and just decisions as to charge. The comprehensive conclusions exceeded the findings of other national investigative agencies.
    • Lucy also advised on a rights issue matter, assessing the culpability of the bank in its issue of shares prior to the financial crisis.

    Recent Criminal Trials

    R v T (2016-2018)
    International tendering corruption case. Defending a procurement consultant to the World Bank and UNDP (United Nations Development Programme). The defendant was accused of entering into corrupt agreements, over six years, with medical supply companies across Europe regarding their bids for World Bank and UNDP tenders. The tenders were for the supply of medical equipment to hospitals and laboratories across Eastern Europe and Central Asia, totalling £43 million.

    R v B (2017-2019)
    Defending, in a number of trials, the CEO of a major international charity accused of multiple counts of defrauding the charity and receiving facilitation payments. Lucy is presently instructed to defend in the complex confiscation proceedings.

  • Undaunted, whether in a tribunal hearing in London or a boardroom in Monaco, Lucy Kennedy’s experience and proficiency enables her to bring focussed, practical and highly effective approaches to the financial regulatory challenges faced by her clients.

    Financial Regulatory

    • Representing banks and bankers: multi-jurisdictional financial regulatory remediation projects and interbank fraud investigations.
    • Financial Conduct Authority: advising and leading a team on a global interbank regulatory misconduct investigation.
    • Appearances before the Regulatory Decisions Committee of the FCA.

    Lucy’s financial regulatory experience stems from her having worked inside both the FCA and also inside the banking sector – leading teams in each.

    Recent Instructions Include:

    • At the Financial Conduct Authority she:
      • Led a team investigating a global bank suspected of international and large-scale money laundering regulatory breaches. Assessing liability and advising on investigative focus and direction in relation to breaches in governance and control at Group level.
      • Assisted Chief Counsel in Criminal Enforcement.
      • Advised on Approved Person Regime supervision and enforcement.
      • Advised on FSMA breaches.
      • Headed, and brought to charge, a multi-million pound investment scheme investigation. Appearing before the RDC.
         
    • Defending a Global bank against the FCA. For over a year, Lucy led a team of sixteen financial crime barristers and several financial analysts located in banks in the UK, Europe and the US in assisting a well-known major bank in addressing urgent and fundamental regulatory obligations and possible breaches.

      She guided her ‘front office’ based team in working directly with bankers and senior executives on topics including:
      • International conglomerate KYC and associated beneficial ownership issues;
      • Cross-jurisdictional trusts KYC and associated beneficial ownership issues;
      • Secrecy and offshore jurisdiction complexities;
      • Cross-platform complexities;
      • Sovereign wealth funds;
      • Bearer share regulations in various countries;
      • Asset assessment;
      • Sanctions restrictions;
      • AML Source of Wealth and Source of Funds evidential analysis;
      • Advising, in person, national-level boards and highly senior executives;
      • Training and providing verbal and written practical guidance to bankers on regulatory requirements in various countries. 

        The remediation project was successfully completed on target, with the regulator highly satisfied.
         
    • Instructed by a global bank to analyse voluminous intricate records and author an extensive report into assertions of money laundering breaches stemming from offshore correspondent banking.

    Conferences/Seminars

    Lucy has convened and curated seminars and conferences, including:

    • Brexit: An Assessment of Where We Really Are, with Sir Ivan Rogers, the UK’s former Permanent Representative to the European Union.
    • The Rising Impact of Sanctions on Business. With a panel of experts, themes included: ‘How banks are tackling the sanctions landscape’, ‘Sectoral sanctions’, ‘The increasing use of sanctions in corruption cases’, ‘Russian entities and their political nexus: a case study’.
    • Some Banking Topics Made Simple. With industry specialists, Lucy addressed topics such as ‘How the Trading Floor Really Works’, ‘A Day in the Life of a Money Laundering Reporting Officer’, and ‘The ‘FinTech’ Revolution’.